United States Office of Personnel Management

The Federal Government’s Human Resources Agency

Benefits Administration Letter

Number: 22-203 Date: March 14, 2022 

Subject: Changes to Acceptable Signature 

Requirements for Federal Employees’ Group Life 

Insurance (FEGLI) Forms 

Healthcare and Insurance previously published BAL 21-203, Forms 

Processing During Disruption of Agency Operations, on May 25, 2021 

to provide guidance to agencies on how to process FEGLI forms during the

disruption to normal agency operations due to the COVID-19 pandemic.

This Benefits Administration Letter (BAL) communicates new changes to

signature requirements for the FEGLI Program and supersedes BAL 21-203. 

Acceptance of Electronic Signatures on FEGLI Forms 

The Office of Personnel Management (OPM) will now permanently allow the

use of electronic and digital signatures on all FEGLI forms submitted to

employing agencies and OPM’s Retirement Services. Agencies are

encouraged to implement the new changes effective immediately.

Electronic signatures are defined as electronic forms or documents that

contain a “wet” or digital signature, that is made into a photocopy,

converted to a PDF or other type of electronic document, and then submitted

to OPM. The two terms may be used interchangeably throughout this BAL

and in accordance with 5 C.F.R. § 850.106.

These changes are made in accordance with Title 5, Code of Federal

Regulations § 850.106, which allows electronic signatures on forms related
Benefits Administration Letter 22-203

2 

to federal retirement and benefit programs. Forms submitted in accordance 

with this BAL will be accepted as valid, and no additional documentation 

regarding signatures will be required. If the requirements for valid electronic 

signatures are not met, agencies will be expected to resubmit 

documentation that is consistent with the new electronic signature 

requirements for FEGLI forms.

OPM will continue to monitor the potential risk regarding the use of 

electronic and/or digital signatures and reserves the right to make changes 

to this policy as conditions change. 

FEGLI Forms That Will Now Allow Electronic Signatures

OPM will accept electronic and/or digital signatures from active employees, 

Human Resources personnel, Payroll office personnel, and witnesses to 

certify the following FEGLI forms: 

FEGLI Form Acceptance of 

Electronic Signature

Requirements

SF 2817, Life Insurance Election YES

SF 2818, Continuation of Life 

Insurance Coverage as an 

Annuitant or Compensationer

YES

SF 2819, Notification of Conversion 

Privilege

YES

SF 2821, Agency Certification of 

Insurance Status

YES

SF 2822, Request for Insurance YES
Benefits Administration Letter 22-203

3 

FEGLI Form Acceptance of 

Electronic Signature

Requirements

SF 2823, Designation of Beneficiary YES Insureds can have two individuals 

witness their signatures through a 

virtual environment. 

Agency personnel may witness the 

execution of the SF 2823 as long as 

they are not named as the beneficiary. 

RI 76-10, Assignment of Life 

Insurance

YES Insureds can have two individuals 

witness their signatures through a 

virtual environment. 

Agency personnel may witness the 

execution of the RI 76-10 as long as 

they are not named as an assignee.

FE-6, Claim for Death Benefits YES

FE-6 DEP, Statement of Claim, 

Option C

YES

Acceptable Methods of Electronic and/or Digital Signatures

OPM will now accept a wide range of electronic and digital signatures on all 

FEGLI forms. Acceptable electronic signature methods include:

1. Personal Identity Verification (PIV) or Common Access Cards (CAC) 

certificate authenticated signatures (PDF documents may be signed using 

the PIV/CAC method and then be printed. Please see BAL 12-102 for 

more information on acceptance of photocopies and scans of signed 

documents). 

2. Electronic or digital signatures signed in accordance with 15 U.S.C. §§ 

7001, 7021, and 7031 (please see the requirements listed below) 

submitted by agencies which must keep the associated record that 

reflects the process by which the signatures were created. 

3. Signatures created through a third-party software, such as DocuSign, 

HelloSign, Adobe Sign, or other agency approved third-party software. 
Benefits Administration Letter 22-203

4 

The electronic signature created must comply with 15 U.S.C. §§ 7001, 

7021, and 7031. 

Requirements for Valid Electronic Signatures:

In accordance with 15 U.S.C. §§ 7001, 7021, and 7031 on facilitating the 

use of electronic records and signatures, OPM will consider an electronic 

signature valid if it meets the following major requirements:

1. Intent to sign – Electronic signatures, like traditional wet ink signatures, 

are valid only if each party intended to sign the document.

2. Consent to do business electronically –All parties signing the document 

agree to conduct the transaction using electronic means. This consent may 

be expressed or implied in that all parties agree that the electronic 

signatures appearing on the document are the same as “wet” signatures 

for the purposes of validity, enforceability, and admissibility.

3. Association of signature with the record – In order to qualify as an 

electronic signature under 15 U.S.C. §§ 7001, 7021, and 7031 the system 

used to capture the electronic signature must keep an associated record 

that reflects the process by which the signature was created or generate a 

textual or graphic statement (which is added to the signed record) proving 

that it was executed with an electronic signature. This is done when the

electronic signature is time stamped on the electronic document at the time 

it is signed and is saved as part of a PDF document.

4. Record retention –The law also requires that electronic signature records 

be capable of retention and accurate reproduction for reference by all 

parties or persons entitled to keep the contract or record. Agencies can 

accomplish this by following the standards of OPM’s Guide to Personnel 

Recordkeeping. 

Agencies should ensure that the digital signature technologies and 

methods adopted are compliant with Federal disability access 

requirements. Agency staff should be trained to use any of the 

accessibility features embedded in agency software and should be 

capable of assisting Federal employees with disabilities on how to submit 

a digitally signed document and application.
Benefits Administration Letter 22-203

5 

Recommended Steps Agencies Should Follow To Ensure 

That Electronically Signed Documents Are Valid And 

Trustworthy

To ensure documents with electronic signatures are created in a valid and 

secure manner, an agency should:

• Create and maintain documentation of the systems used to create the 

records that contain electronic signatures.

• Ensure the records that include electronic signatures are created and 

kept in a secure environment that protects the records from 

unauthorized modification or destruction.

• Implement standard operating procedures for the creation, use, and 

management of records that contain electronic signatures, and keep 

adequate written documentation of those procedures. 

• Create and keep records according to these documented standard 

operating procedures.

• Outline steps to validate an electronic signature in the standard 

operating procedures. 

• Train agency personnel in the established standard operating 

procedures.

Common questions about electronic signatures for FEGLI

forms

1. What does OPM mean by allowing “electronic” and “digital”

signatures on FEGLI forms?

OPM will now accept FEGLI forms included as part of a retirement 

package to be electronically or digitally signed. The term “digital 

signature” means a signature that has been created by software that

contains an authentication certificate and includes the individual’s name, 

date and time of signature. Examples of these types of software include 

Adobe Acrobat or DocuSign. The term “electronic signature” means 

electronic forms or documents that contain a “wet” or digital signature, 

that is made into a photocopy, converted to a PDF or other type of 

electronic document, and then submitted to OPM. The two terms may be 
Benefits Administration Letter 22-203

6 

used interchangeably throughout this BAL and in accordance with 5 C.F.R. 

§ 850.106.

2. Are electronic signatures required on FEGLI forms? 

No. The use of an electronic signature to sign FEGLI forms is optional. 

Employees and agency personnel may still sign FEGLI forms with a “wet 

signature” or submit photocopies of signed documents directly from an 

official system of records in the custody of the agency.

The use of an electronic signature is available to employees who have the 

ability to sign or certify FEGLI forms electronically and would like to do 

so. 

3. Who is allowed to submit forms with electronic/digital 

signatures? 

Employees, agency personnel, and witnesses, as applicable, are allowed 

to electronically sign FEGLI forms or other types of non-agency 

transaction when such signatures are required on those forms.

4. How can employees and agencies sign the forms electronically or 

digitally?

Most FEGLI forms are Adobe Acrobat fillable forms and may be completed 

and signed by PIV or CAC authentication. Employees, and witnesses who 

use other third-party software will need to follow the instructions in 

accordance with the digital signature software being used. Regardless of 

the method used, the electronic record must be tamper-proof once it is 

electronically signed in accordance with 15 U.S.C. §§ 7001, 7021, and 

7031. 

Agency personnel must use a government issued PIV/CAC card. Please 

see Attachment A for instructions on how to sign FEGLI forms using a 

PIV/CAC card.
Benefits Administration Letter 22-203

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5. Can FEGLI forms containing electronic and/or digital signatures

be submitted through alternate methods besides regular mail

(i.e., email or fax)?

No. OPM has not established an alternate process to accept FEGLI forms 

through any other submission method.

6. What if an employee does not have a PIV or CAC card?

Employees and witnesses who use other third-party software will need to 

follow the instructions in accordance with the digital signature software 

being used.

7. Can annuitants sign FEGLI forms electronically or digitally?

No. Electronic or digital signatures are not available to annuitants at this 

time, because annuitants no longer have PIV or CAC cards from their 

former government agency and the agency must retain the administrative 

record for these signatures. We hope to allow the ability for annuitants to 

sign documents digitally in the future and will continue to assess the 

various types of acceptable signatures that would be acceptable for this 

purpose. 

If you have any questions regarding this BAL, please contact the Life and 

Ancillary Benefits group at FEGLI@opm.gov or call (202) 606-1413.

Sincerely,

Laurie Bodenheimer

Associate Director

Healthcare and Insurance

Enclosure:

Attachment A, Digital Signature Instructions
ATTACHMENT A

Personal Identity Verification (PIV) and Common Access Cards (CAC) 

Digital Signature Instructions 

1. Complete all required fields on the fillable FEGLI form. 

2. Save the document as a Portable Document Format (PDF).

3. Open the newly saved PDF and select Tools from the menu bar above. 

4. Under “Forms & Signatures”, click “Certificates”. 

5. You will be taken back to the signature page of the PDF. You will note a new menu bar 

toward the top of the screen. Select the Digitally Sign option from the menu bar above. 

6. You will then have to outline the box in which you will need to digitally sign. 

7. You will be prompted to enter your PIV or CAC passcode. Once the document is 

digitally signed, save the document again.